ML20045E164
| ML20045E164 | |
| Person / Time | |
|---|---|
| Issue date: | 06/24/1991 |
| From: | Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| To: | Sharon Hudson NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20044B465 | List: |
| References | |
| FRN-57FR33426, RULE-PR-70, RULE-PR-72, RULE-PR-73, RULE-PR-75 AD03-2-011, AD3-2-11, NUDOCS 9307010200 | |
| Download: ML20045E164 (2) | |
Text
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i WASHINGTON, D, C. 20555 MUN 2 41991 iss
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HEMORANDUM FOR:
Shirley H. Hudson Information Management Coordinator; Office of Nuclear Regulation Research Robert L. O'Connell..
Information Management Coordinator Office of Nuclear Material Safety and' Safeguards FROM:
Brenda Jo. Shelton,. Chief Information and Records Management Branch.
Division of Information Support Services-Office of Information Resources Management
SUBJECT:
COMMENTS ON FINAL RULE, 10 CFR PARTS 70,.72, 73, AND 75, " MINOR AMENDMENTS.TO THE PHYSICAL PROTECTION REQUIREMENTS" Our review of the " Federal Register Notice" for the subject final rule indicates-that the Paperwork Reduction Act Statement-is correct ~and there is no'need to modify the related "Information Collection Requirements: OMB Approval" sections as a result'of this rulemaking. However, as a result 'of a separate effort to compile a~ complete listing sf NRC reporting and recordkeeping requirements, we noticed some inconsistencies in several~'of'the:
recordkeeping. requirements that are included in~this rulemaking. Our initial-plan was to request guidance on the issue when we circulate the listing for-review and comment, but s;nce we are commenting on the final rule, we are surfacing the issue now fo, your consideration.
We found what appears.to he inappropriate retention periods-(three ' years) for changes to the " Physical St.curity Plan" pursuant t'o section 70.22(k), and-the
" Safeguards Contingency al Procedures" pursuant.to section 70.32(g). These are inconsistent with rete 1 tion periods cited elsewhere in the regulations.
Sections 70.32(g), 73.46(h), 73.50(g)(1), and 73.55(b)(4)(ii) direct licensees-to retain changes to documents, such as the " Safeguards Contingency Plan" and the " Guard Training and. Qualification Plan, for the same period 'of time as the main dacument,'normally until termination of-license or for the duration of the pcssession of the licensed material. The superseded material is retained for three years after a change is effective, not the new changes. Sections 70.22(j)(3) and 70.32(d) and'(e) also contain this discrenancy in retention requirement.
9307010200 930512 N57 33426 PDR
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If you have any questions regarding our comments, please contact Michael Collins on extension 28044.
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, Chief Information d ecords Management Branch Division of In ormation Support Services Office of Information Resources Management cc:,SeTurel,!RESg P. Dwyer, NMSS s
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